Child-lens investing in digital infrastructure investments
Finnfund is among the first investors putting Child-Lens Investing into action through a growth-oriented impact fund focused on digital and financial inclusion.
Finnfund is a valued partner of the UNICEF Innovative Finance Hub and an active member of our Child-Lens Investing Community of Practice (CLI CoP). By applying the Child-Lens Investing Framework (CLIF) in their Digital Access Impact Fund, Finnfund is supporting investments that improve the lives and futures of children.
We asked Harold Gordillo, Environmental and Social Adviser at Finnfund, a few questions about their fund that applies a child lens, their stewardship work and advice they would offer to other investors in working for positive child outcomes.
1. Could you briefly describe Finnfund’s Digital Access Impact Fund?
Finnfund’s Digital Access Impact Fund I (DAIF) is a growth-oriented impact fund focused on narrowing the digital and financial inclusion gap through investments in digital infrastructure and digital solutions in emerging and frontier markets. It targets equity and equity-like investments in businesses that can expand access, improve affordability and reliability, and make digital access more meaningful for underserved populations.
The fund’s geographic focus is Africa, Latin America and Emerging Asia. The fund finances businesses such as fibre networks, mobile networks, submarine connectivity, data centres, telecom towers, shared infrastructure and scalable digital services, including fintech, insurtech, healthtech, edutech and agtech. Its impact framework also includes Child-Lens Investing and Gender-Lens Investing. DAIF reached its first close in August 2025 with EUR 80 million of commitments, and its stated target size is EUR 150 million, with a hard cap of EUR 200 million.
2. Which child related risks are you paying particular attention to within the Digital Access Impact Fund?
DAIF has four child-specific targets:
1) No child labour in our portfolio companies' operations, in their contractors' operations and in their supply chains
2) All portfolio companies support their employees in their roles as caregivers
3) 100% of portfolio companies' employees' school-aged children go to school
4) 100% of portfolio companies' employees are trained in children's rights
Within DAIF, we pay particular attention to child labour, young workers, and adverse impacts on the rights of children, parents and caregivers across company operations, contractors, subcontractors and supply chains. Our internal CLIF process requires enhanced due diligence on detrimental impacts on children’s and caregivers’ rights, including working conditions and terms of employment for direct workers and those in business relationships. We also assess impacts on children in project-affected communities, recognising children as a distinct stakeholder group in infrastructure projects and considering risks associated with unsafe work sites, land acquisition, pollution, displacement, community engagement, and accessible grievance channels.
In the digital context, we also examine risks and opportunities for children who use or benefit from products and services such as internet connectivity. Our due diligence asks how children’s wellbeing may be affected online, whether safeguards such as parental controls are in place, how child-related data is protected, and whether governance, training, and escalation procedures are in place to respond to child-safety risks. We therefore screen for exposure to harmful digital content, online exploitation and abuse, predatory contact, and privacy breaches.
3. What changes have you made to your due diligence processes to account for those risks?
We have adjusted our due diligence by adding a child lens through theme-specific questions to the standard DDQ. We conduct an analysis that extends beyond direct employees to contractors, subcontractors, and supply chains, when possible, and helps the E&S adviser to identify child-related risks, adverse impacts, and practical mitigation measures. The Standard Operating Procedure (SOP) guides the Environmental and Social (E&S) review toward Environmental and Social Action Plan (ESAP) design, incorporating UNICEF’s expertise on child rights. This includes, for example, additional child-related considerations and assessment questions that go beyond the IFC Performance Standards to ensure that child rights are more effectively integrated into action items.
We also try to go beyond standard questionnaires. Our guidance includes focused group interviews during due diligence with parents, caregivers, and workers in caregiver roles, especially during on-site visits, to determine whether the company is genuinely promoting a family-friendly workplace. The findings are analysed against the IFC Performance Standards and translated into concrete measures, such as child-rights policies, child-sensitive grievance mechanisms, and stakeholder engagement plans that explicitly include children, parents, and caregivers.
4. What child-friendly policies and practices do you prioritize with investees?
We prioritise family-friendly workplace policies that help workers fulfil their roles as parents and caregivers.
These policies include:
- Flexible working arrangements
- Paid leave
- Childcare support
- Emergency leave for family matters
- Breastfeeding support
- Broader protection of basic labour rights.
We also prioritise practical measures that improve children’s wellbeing more directly, such as staff training on children’s rights, and robust action to prevent child labour in operations and supply chains.
We also look for child-sensitive management systems. These include a child rights policy, targeted staff training, grievance mechanisms that are accessible and safe for children or those acting on their behalf, and stakeholder engagement processes that recognise children, parents and caregivers as key stakeholders.
In addition to ensuring that all necessary policies are in place, we conduct at least one external, independent survey with each of our investees where we ask employees whether and to what extent these policies are enforced and enable them to act as caregivers.
5. What has been working well and what challenges have you encountered when integrating a child lens?
What has worked well is that a child lens is now embedded in DAIF’s investment process rather than treated as a standalone topic. Finnfund has collaborated closely with UNICEF, developed child lens screening tools, and applies them to identify risks and practical mitigation measures. The modified due diligence questionnaire has also worked well by helping structure more focused analysis. We are also looking forward to rolling out a free online training for our investees on child rights and due diligence processes to strengthen capacity in a practical way.
The main challenge has been operationalizing a child lens in a way that is sufficiently practical and sector-specific. For instance, digital sector introduces new risks, such as cybersecurity, digital rights, and harmful online exposure, which require additional tools and adaptation. One area we continue to work on is adapting certain children’s rights considerations to ICT and digital infrastructure projects and translating them into realistic ESAP actions. More broadly, one challenge is that children’s rights must be integrated alongside several other critical themes already covered in our analysis, including climate change, biodiversity, human rights and supply chain risks.
“What has worked well is that a child lens is now embedded in Finnfund Digital Access Impact Fund’s investment process rather than treated as a standalone topic.”
6. How are you supporting investees to begin aligning with child lens requirements or to provide child related risk data?
We support investees in several practical ways. First, we use the modified child lens due diligence questions and translate identified gaps into concrete ESAP requirements, including child rights policies, child-sensitive grievance mechanisms, stakeholder engagement measures and, where relevant, training obligations. Second, we share targeted guidance and tools, including UNICEF’s family-friendly workplace resources and broader child rights materials, to help companies strengthen their internal systems and workplace practices. Third, we are rolling out a free online CLIF training for investees to build capacity in child rights and due diligence, and we are also using surveys and verification questions to generate child-related data and assess child-friendliness in practice.
7. In what ways could UNICEF support investors to integrate CLI into their ESG strategies and processes?
UNICEF could best support investors by continuing to translate child rights into practical tools and capacity-building support. This means additional concise screening tools, tailored due diligence questions, example ESAP actions, and targeted training for both investors and investees.
8. What advice would you offer to other investors looking to integrate a child lens into due diligence processes?
My advice would be to embed a child lens into existing due diligence rather than treat it as a separate exercise, and to begin with a small set of practical, sector-relevant screening questions that help identify where heightened analysis is really needed. It also helps to link findings directly to your existing E&S architecture, especially the IFC Performance Standards, so that child-related risks are translated into realistic ESAP actions. Just as importantly, invest in capacity: practical guidance, and targeted training make it easier for both investors and investees to move from good intentions to consistent implementation.
